Orange County Tax Attorney Blog

What is an IRS jeopardy levy

What Is An IRS Jeopardy Levy?

When the IRS “makes a finding that the collection of such tax is in Jeopardy,” the IRS can make notice and demand for immediate payment and, […]
tax attorney newport beach, tax attorney orange county, estate planning attorney newport beach

Application of the Local Action Doctrine in Federal Tax Lien Cases

A “Local Action” is an action that must be brought in the state where the property is located.  A taxpayer or third party seeking to clear […]
tax attorney newport beach, tax attorney orange county, estate planning attorney newport beach

How Long Do You Have to File a Complaint in District Court Once a Refund Claim is Rejected by the IRS?

  Under 26 U.S.C. § 6532(a)(1), a taxpayer generally may not wait longer than 2 years from the issuance of the IRS’s disallowance of the administrative […]
orange county tax audit

Release or Discharge of Property from a Third Party’s Federal Tax Lien

  When a Federal tax lien for one person is erroneously filed against another person’s property, that tax lien may cause an escrow company to pay […]
tax attorney newport beach, tax attorney orange county

Snipes v. Commissioner, T.C. Memo. 2018-184

  T.C. Memo. 2018-184 UNITED STATES TAX COURT W.T. SNIPES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27902-15L. Filed November 1, 2018. P has […]
tax attorney newport beach, tax attorney orange county, estate planning attorney newport beach

Salt Lake City District Court Bars Pair from Promoting Solar Tax Credit Scheme

  A recent release by the United States Department of Justice covered a $50 million-dollar judgement against two individuals and two companies. The full release can […]

California CPA Pleads Guilty to False Return in Relation to Money Illegally Siphoned From Religious Non-Profit

The FBI issued a press release earlier this week, giving publicity to yet another example of a tax prosecution intermingled with abusing a position within a […]

IRS Improperly Withholding Documents In Response to Freedom of Information Act Requests

On September 18, 2015, the Treasury Inspector General for Tax Administration (TIGTA), a bureau of the department of the Treasury, issued its Fiscal Year 2015 Statutory Review […]

IRS Raking It In through Offshore Voluntary Disclosures, Encourages More OVDP

WARNING: Update 3/13/2018.  The IRS has announced the formal Offshore Voluntary Program discussed below will be closed on September 28, 2018.  For more, see our post […]

7 Defendants Found Guilty in $33 Million False Refund Scheme Using False 1099-OIDs

On Tuesday, the Department of Justice issued a press release announcing that seven Fresno-area men were found guilty of participating in a scheme in which they […]

Tax Court Rejects Frivolous Filing Penalty for Taxpayer Invoking the Fifth Amendment in Tax Return

On November 6, 2015, the United States Tax Court issued its opinion in Youssefzadeh v. Commisioner, Docket No. 14868-14L, in which it held that the taxpayer […]

Southern California Doctors Indicted Under Tax Charges in Alleged Kickback Scheme

The Los Angeles United States Attorney’s Office is prosecuting related cases involving doctors and an alleged kickback scheme.  The principal charges involve mail fraud, money laundering, […]

San Diego Area Return Preparer Pleads Guilty to ID Theft and Admits to Over 4000 False Returns

A Miramar return preparer pleaded guilty on December 2, 2015, in the San Diego Federal District Court.  As we head into the next filing season, we […]

Tax Court Issues Opinion in Sumner Redstone v. Commissioner, T.C. Memo. 2015-237

The United States Tax Court recently released its opinion in the Sumner Redstone case.  The case is notable not just because Redstone is a media magnate, […]

Canadians Take Advantage of U.S. Tax Scheme

Tip of the hat to Rochester Business Journal for their article this month highlighting one instance of Canadians coming across the border to enjoy the [illegal] […]

Orange County Man Convicted of Bank Mortgage Fraud Conspiracy and Tax Evasion

Hot on the heels of the success of the movie The Big Short, the United States Attorney’s Office for the Central District of California issued a press […]